It's not the first time the law has gotten involved when Penn has had a run-in with photographers.

He served 33 days in jail in 1987 after assaulting a photog on a film set during his marriage to Madonna. According to some accounts, he hung that paparazzo by the ankles from a ninth-floor balcony after discovering him in the actor's hotel room.

Penn was also charged with felony domestic assault during his marriage to Madonna. He pleaded to a misdemeanor.